The Australian Taxation Office has revealed it is pursuing seven global businesses over unpaid tax worth $2 billion and will force the restructure of dozens of companies so they book more profits here.
The inroads on profit shifting emerged on Friday when the ATO released its second annual report on the amount of tax paid by 1904 public and private companies operating in Australia.
At $42 billion, tax collected in 2014-15 dipped slightly (down $59 million or 0.1 per cent) and the proportion of companies paying zero tax remained constant about a third.
The ATO said falling commodity prices had translated into less tax payable for the energy and resources sector, while manufacturers, financial services and technology companies contributed more.
BHP, for example, went from the biggest taxpayer last year to the 6th position this year.
Household names including the big four banks, two supermarkets, miners and Telstra were among the top 10 taxpayers.
The figures did not yet reflect the effects of Australia's Multinational Anti-avoidance Law (MAAL), tax avoidance taskforce or proposed diverted profits tax, Tax Commissioner Chris Jordan said.
Moreover, no tax paid did not necessarily mean tax avoidance, he said.
"Even companies with very high total income sometimes make losses and you will no doubt recognise some large Australian organisations on the list that fall into this category – Qantas for example."
The MAAL penalises multinationals that use artificial arrangements to avoid the attribution of business profits (and therefore tax) to Australia.
Second Commissioner Jeremy Hirschhorn said 105 companies had been identified as being within the scope of the MAAL.
"Of that high-risk group, we've seen 24 companies fundamentally restructure their Australian operations and we'd expect most if not all of the remainder to also restructure and book their sales in Australia," he said.
"These models are in many industries but primarily focused on industries where it is possible to deliver a service from overseas, and so you will see more of these companies in the e-commerce type area."
And by the end of financial year 2017, the ATO would have issued seven "BEPS-related amended assessments" in pursuance of $2 billion in unpaid tax, Mr Hirschhorn said, adding that he expected several to find their way to court in the same way as the Chevron transfer pricing case had.
BEPS stands for base erosion and profit shifting and has been the subject of coordinated effort by the OECD and G20.
The assessments relate to the use of finance and marketing hubs.
Some companies, such as BHP and Mitsubishi Development , have revealed that they are in dispute with the ATO.
Shadow assistant treasurer Andrew Leigh said it was difficult to believe the Turnbull government's top priority was giving big companies a tax cut when the data showed a third were paying no tax.
The Corporate Tax Association, representing large business taxpayers, said there were a range of legitimate reasons a company might not pay tax in a given year, including deductions for previous years' losses and offsets for research.
The association slammed "supporters of post-truth politics", who were falsely claiming the data showed widespread avoidance.
The Business Council of Australia said: "The tax office's publication of company tax data underscores the fact that Australia has some of the strongest transparency and integrity measures of any country in the world."
